SWORN STATEMENT OF - The New York Times

[Pages:39]SWORN STATEMENT OF

MICHAEL BARNHILL

June 20 , 2016

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PURSUANT TO AGREEMENT the Sworn Statement

of MICHAEL BARNHILL was taken at 720 South Colorado

Boulevard, Suite 1110 - N , Denver , Colordo

, on

June 20 , 2016 , at 10 : 15 a . m . , before Stacy .

12 Armstrong, Certified Merit Reporter, and Notary Public

within Colorado.

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H +G

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303. 832. 5966 800 .525 .8490

, Inc.

1900Grant Street, Suite 1025 Denve,r CO 80203

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Sworn Statement of MichaelBarnhill

MICHAELBARNHILL

SWORN STATEMENT OF MICHAEL BARNHILL

June 20, 2016

PURSUANT TO AGREEMENT, the Sworn Statement of MICHAEL BARNHILL was taken at 720 South Colorado Boulevard , Suite 1110- Denver , Colordo 80246 , on June 20 , 2016 , at 10 : 15 a . m . , before Stacy L . Armstrong , Certified Merit Reporter , and Notary Public within Colorado .

DE EXAMINATIONOF MICHAEL BARNHILL: June 20 , 2016

By Mr. Bussey

6 20 / 2016

PAGE

2

A PP

ARA

C

TIMOTHY R BUSSEY , ESQ .

The Bussey Law Firm , P . .

12 East Boulder Street

Colorado Springs, Colorado 80903

RHIDIAN D . W . ORR , ESQ . The Orr Law Firm LLC 720 South Colorado Boulevard Suite 1110 - N

Denver, Colorado 80246

VINCENT C . TODD , ESQ. Coloradowrits 12600 Est Colfax Avenue Suite C400 Lakewood, Colorado 80215

WHEREUPON , the following proceedings were

had:

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MICHAELBARNHILL,

havingbeen first duly sworn to state the whole truth, stated as follows:

EXAMINATION BYMR. BUSSEY:

Q All right. Well , let's start off . Please tell us your name, and are you employed right now ?

A . MichaelBarnhil;l go byMike. Yes, 'm employed I ' m self-employed.

Q . Okay.

A . I have a company, M & D Enterprises, and I run

two little businesses under it, and I stay generally busy .

Q . All righ.t Haveyou previouslyworked for the ColoradoDepartmentof PublicHealthand Environmen?t

A . I have. Q . And just for the sake of brevity, we'll refer to that as your former job or CDPHE? A That' s fine. Q . What did you do at CDPHE ? A . The official position was Electronics

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Sworn Statement of Michael Barnhill

MICHAEL BARNHILL

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Specialist III. I worked in the EBAT program , E - B - A - T . The tasks included hands- on tasks:

calibrating and repairing Intoxilyzers. The career was a little over five years . Iwas the work lead of the little lab there . And so the tasks then became

quite a bit more varied as timewent on.

Q. How long did you work there? A . A little over five years, so -- Five years, three months. Q. Okay. From when to when ?

A . Sure. November 2009 till very early March 2015 .

Q. Okay. Who was your supervisor during that

period of time ?

A . Jeff

.

Q . And what was his position ?

A . He was the program manager, the EBAT program

manager

Q . Okay. For yourposition, whatwere the

qualificationsthat were required? A . Electronicstechnologybackground. Thatwas

primarilywhatthey were seeking. Somemetrology background.

Q . What was your prior experience concerning those requirements?

A . Largely training on- site from -- from the lab , from CDPHE. Went off -site to CMI for training as well, and then annual conferences hosted by CMIwhere there are additional trainings .

Q . Okay. So your primaryeducatoron this device was CMI? If therewas others, justlet us know .

A . Yeah , you know -- No; I think the primary educator was CDPHE , just because that's where you were every day . And so almost all of the details learned and known came from the day -to -day experiences.

Q. Okay . And with the 5000 EN there was a pointwhere it was determined that the State of Colorado needed an updated device ?

A . Yes .

Q . Did you participate in the selection for thatdevice ?

A . Yes. Q . Whatwasyour -- Whatpurpose -- Whatwas your role? A . Sure. The -- If I remember right, there were five of us on a selection committee , three ofus within the lab, fiscal , and -- oh, gosh , there was one other. Q Was there a contracts person ?

A . Sure. I' d had 18 years of experience in the electronics industry , repair and service, had about a year and a half experience in the metrology

profession , working for Honeywell. That wasmy prior background . More than 18 years . 22 or 3 years at

that pointof electronics industry background.

Q . What specialized training, just

,

haveyou had concerningelectronics?

A . Oh, gosh . Generaltrade school--

Q Okay.

A . - - education. And then certainly just years of experienceof this work.

Q . What was your job prior to joining CDPHE?

A . I was self- employed. I ran a small store

doing musical instrument repair.

Q . All right. And when you applied for the position of electronics specialist for CDPHE , what did

they advise you you were going to be doing? A . They told meit was test and calibration of

breath alcohol instruments. Q . Okay. So in 2009 the device thatwasused

in Coloradowas the Intoxilyzer5000 EN ?

A . Sure.

Q . What training did you receive on the 5000 EN ?

A . Contracts person. Thank you. Yeah . Q. Do you remember their names? A . Rick Brough was our fiscal person, contracts

person, was the man in charge of the State contracts. If you rattle off some names, I' ll recognizeit. But it wasmyself, Bob McDuffee, and Jeff Groff were the

three program people. Q Who was the person primarilyresponsible for

the selection ofthe device to replacethe 5000 EN?

A . Well, the way the -- the way the selection went , there was no single person that made a decision . Obviously , Jeff, being the program manager, and Rick

Brough , the finance person and the contract person, kept us separated in that manner so that we all did

our piece of it. And we each scored the thing on its

merits, the devices on their merits , and literally opened the envelopes and discovered what the next --

what the choice would be.

Q . You' re familiar with the requestfor proposa?l

A . Yeah .

Q . Who prepared the request for proposal

A . You know , I don' t know if it was Rick or if

it was Tim . The contracts guy was Tim . Starts with

25

an M . I don 't know who did .

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Sworn Statement of Michael Barnhill

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6 / 20 / 2016

Q . Okay . And when we talk about a request for proposal, we' re talking about what the State of Colorado will want out of the new device , right?

A . That's my recollection, yeah . Q . And did you see any drafts of the request for proposalbeforeit was sent out?

A . Sure.

Q How was this being communicated to you concerning the request for proposal? Was it e-mails ?

A . Some, yeah . Some just -- I' d be atmy desk and Rick or Tim would call and have a question , or Jeff. You know , we would just talk amongst ourselves as we developed -- as we developed the -- the various specifications that we wanted.

Q . You were looking for a particular criteria of things that you would like to see in the next device that they purchased ?

A . Absolutely , yeah. Q . Was thereany communicationwith

manufacturersor research from manufacturersas to what devices were on themarketat the time?

A . Yeah.

Q . What did thatconsistof, if you recall?

A . Well, weknew -- Therewere four primary --

25

I think there were five worldwideat the time, but

11

devices were out there ? A . Right. Well, what devices, but what

capabilities were out there too . Q . During this process, when the sales teams

were coming out, was there any product that particularly drew your attention or the attention of somebody from CDPHE as standing out as a better product than another one ?

A . No. I mean, in those early stages, no, there wasn 't. I mean -- and I guess I speak for myself . I mean , they were all just sort of - each one of them had their interestingthings. I can speak for myselfand say , yeah, there was one thatwas more intriguing than another. But, as a group, no, I don 't think any ofus walked around saying, ooh, this or that.

. Did CMIdo a presentation before the request for proposal on the Intoxilyzer 9000 ?

A . I don' t recall.

Q . But they had been in contactwith you concerningsomeof their products?

A . Yeah . Yeah . Q . All right. Now -A . May I ? Q . Go ahead, please.

10

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four primary thatwe thoughtwould have access to -that would bid on the job . We, from just basic Internet searches and looking at their products that

way , had known oftheir general specifications and capabilities. Wehad - - Before the process started formally , the folks from Drager had come and been in touch with us, you know . Intox - - What was the - What' s that company outofOhio that just merged ? Well, a couple of other companies and CMI. I mean , they all knew wewere going to be in themarket, and so they sent their sales staffs out periodically to , you know , talk to us , that kind of thing.

Q . So theywould send out - - These various manufacturerswould send outkind of a sales team to

comeout --

A . Sure.

Q. -- and give you an overview of their product -

A . Sure . Q . -- so that you could review what they had?

A . And that wasbeforethe process formally started.

Q . Understood. A . Yeah

Q You were trying to get a feel of what

A . Did CMI do a presentation ? No. I mean , we knew that the 9000 was in development. Did they do a presentation ? No. I mean, we knew what they were going to propose .

Q . How did you know that ? A . , gosh . Just in the conversations that we' d had. You know , they 'd been our vendor for years .

We attended their annualusers group conference . You just know , you just know what s going on, so .

Q So when you attend the annualusers group meetingsfrom CM,I are those located throughoutthe country?

A . Sure, they are. Q . And they' re typically two days? A . I think they were three days. Wewould

arrive on a Sunday, return on a Thursday. So Monday,

Tuesday , Wednesday All right. When you went to these, there' s

other users from acrossthecountry thatarethereas well ?

A . Absolutely.

Q . So its really state representativesthat

use the Intoxilyzer? A Yeah . There were a few from various

25

military bases around the world , but generally yes,

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Sworn Statement of Michael Barnhill

MICHAEL BARNHILL

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state - levelpeople.

Q . And when you attended these users group

Q . So it was really a networking opportunity to see how the others could make the device work better

meetings, did JeffGroff normally appear ?

or implement a device better ?

A Nottypically.

A . Ofcourse.

Q . Okay . So was itmore than one person from

Q . So prior to the selection processfor the

CDPHE were you the primary person, or --

o

9000, you had somefamiliaritywith the Intoxilyzer

A . So Jeff would send all of us technicians ,

8000, for example?

you know , just whoever the lab people were . He

A . No. And specifically for me, and I don ' t

wouldn 't send Rhonda. Rhonda was the program administrator

Q . What 's Rhonda ' s name?

know about the other coworkers in the lab , but I didn ' t go to any of the break -out sessions on the 8000 .

A . Webb

We -- My own take on it, I was going to

Q . Okay .

attend the sessions on the 5000 EN, sessions on the

A . And she' s passed away at this point. But,

Guth simulator that we used, sessions on breath

yes, itwould bemyself and the other coworkers in the

alcoholtesting in general, because that's what we

lab . Rick Bates, new name, wasn 't -- he was ill

o

did. And it was possible that wewould select an

duringmy early tenure at CDPHE, and so hewouldn' t

8000 , but I didn 't need to spend my time looking at

typically attend. Jeff didn' t typically attend. Jeff attended the users groups in Colorado and the one

that until we'd made that choice , if we had .

o

I don' t remember attending -- They really

before that in Montana, Missoula .

didn 't have any sessions on the 9000 before itwas

Q When a person attends a users group meeting,

actually available . So , yeah , I just didn' t attend

do they normally provide you with materials ?

anything other than what wewere working at.

A . Who 's they ?

. When these requestsfor proposalsare

Q . CMI.

gettingbouncedback and forth betweenyou , did you

A . , sure .

haveinputon things that you as a technicianwould

14

Q . All right. So they would give you documentationor disks or information concerning--

A . They would -- Of course you' d get an -- You know , you check in , you get an agenda. Some of the presenters would make their presentations available so

you could download it to your thumb drive if you wanted; not all did .

Q Are you aware if JeffGroff has given a

presentation at one of the users group meetings ?

A . Sure, he did

Q . What were his presentationsabout? A . , boy. So his presentationin Missoula- -

Did he give a presentationin Missoula? I don' t recal,l Tim

Q . Butyou do recall him giving presentations? A Yeah

Q . Is thatnormalfor other state customers to

give presentations- Sure.

Q -- a CMI--

A . Sure . That' s where the material always came from

Q . Did any of thematerialcome, in fact, from the manufacturerCM?I

A

Sure.

16

look for for the device ? A . Sure Q . What s an example of some of the things ? A . Oh , gosh . Touchscreen , you know , did it

have touchscreen capability . Often - - I say often . Tim , there were probably three or four times that Rick or Tim Massingale, that' s who 'm thinking of, the contracts man , had a question abouthow they were crafting the RFP. And they couldn ' t reach Jeff , so they called me. And, no , I don 't remember what those

specific conversations were, but that was the level of my input.

Q What time frameare we talking when these conversations were taking place ?

A . Sure . That would have -- That would have had to have been in the three months that preceded the actual publication of the RFP. Dates I don' t know .

Q. Okay . All right. So the basis for

replacing the Intoxilyzer 5000 EN , itwas the issue

with the technology was old at that time?

A

Yeah .

Q . Is that what was goingon ? Why did it need to be replaced

A . Sure. Well, itwas getting to a point where we were having to scavenge some instruments for parts

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for other instruments . Wewere getting into our

posting. And so people in the breath alcohol industry

loaner pool, and it just -- it just was becoming clear that the day would arrive in five or six years where we would really start to deplete the fleet of those

are looking for that sort of thing, and, boom , there' s an RFP from Colorado. That'smy understanding of it .

Q . So it's your understanding that there was a

instruments . Q . Were you - - Were you ever a technician when

there was a second sample available on the 5000 EN ?

posting; you just don 't know specifically how it' s posted ?

A That's correct. I do know that we didn' t

A . I never was . Do you mean the captured

send an RFP to this company or that one. We didn 't

sample ?

specify who to send an RFP to , itwas just this

Q . Yes

general posting concept that I laid out.

A . No is the answer.

Q. How manymanufacturersrespondedto that

Q. Okay. But you wereawarethat thedevice

posting, if you recal?l

had previouslyhad a captured sample?

A . Four.

A . Sure .

Q And who were they ?

Q On the request for proposal , was it ever

A . Sure. CMI. Drager. I want to say

discussed that the new device should have a captured

Intoximeter, and National Patent. National -- Is that

sample ?

the right name?

A.

. Itwasn ' t an option that any of the

Q . I believeit is.

manufacturers had.

A Yeah, NationalPaten.t Fourresponded.

. , to yourknowledge, CMI, for example, which previously had a sample captureoption , was not

Q . And during the time frameof -- You go from the request for proposal now to actually setting up

offering that anymore ?

how you' re going to determinewhich product the state

A . That' s correct Neither were the other

is going to go with . Describe what happened after you

vendors. My recollection is there was only one state , New Hampshire , that was still using a captured sample ,

received responses from thosemanufacturers.

25

A . Sure. The very first step in the process

18

and then therewas only one vendor providingthose - those tubes, if you will. And so noneof the other vendors were building an instrumentthat did that, if I recall

Q . Anddid anybodyfrom thedepartmentof healthsaymaybeweshould consider havinga sample capture?

A No

Q . So for the requestfor proposa,lyou did have an opportunityto review the finalRFP thatwas sentout to themanufacturers?

A Sure .

. You ' ve indicated that there were fouror five manufacturers. Was thatRFP sentout to all the manufacturers?

A . Tim , I don't know exactly how the system works, butmybrief understandingis that when a state puts out an RFP of this manner, they post it on some, I don 't know , some site that -- So ifyou build trucks, you 're constantly seeing who' s looking for -you're constantly checking this, and you see a state pops up, and then you -- and that s how this tended to work. So the state, just through its own -- its typicalprocess of posting this -- and it's an open posting. My understanding is it's just a wide-open

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was we invited anybody who would bid to Colorado . I forget what we called it, but it was a --

( Phone interruption.)

THE WITNESS : Is thatmy phone ? I apologize .

A . They had to come to Colorado on this particular day . There was a question and answer sort of -- we were in a panel up in the training room of the lab. And four manufacturers responded. The four that I just mentioned sent a representative. I forget what the purpose of that was , but itwas a mandatory meeting; that if you - - The basis of it was, if you intend to bid on this project, you have to come to this meeting and do this question and answer thing. So four of them did , all four of them did. Intoximeter bowed out very quickly after that. They realized that they weren' t going to be able to compete with the others.

Q . Do you remember why ? A . Sure . Intoximeter used an electronic cell for measuring breath alcohol content, and we were specifically wanting an infrared system . Q. Why?

It's thoughtto be the standardof the industry.

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Q . So it' s believed that there' s a higher level of accuracy and precision and reliability on infrared ?

for Jeff, Jeff enjoyed the ego trip that came with his position ; dealing with sheriffs , police chiefs,

A . Yeah

attorney generals , staff, this kind of thing. And

( Phoneinterruption.)

thatmade him more micromanagey sic ].

THE WITNESS : I apologize ; let me turn the sound off on this.

So as we gotto this pointwhere this project was going to go forward , we were going to

A . Yes, that is the case. And my recollection

actually start testing these things , and we had these

too is Intoximeter didn' t seek interference . That 's

vendors now in a formal environment, we received these

what I also tend to recall

things, and Jeff started to sort of write outhow we

.

, throughout -- when the selection

process begins , how is it described to you and who

were going to each test these. Hekind of managed that and leftus to do our own testing, of course , but

described to you how this process was going to take place ?

Jeff designed the testing of all of them , which we followed through .

concept of how we were going to do it was described by Jeff and Rick and Tim . Imean , it

And at the time, you know , my own thought was it didn' tmatter, even today I think it doesn 't

o

was just sort of -- And it wasn 't as though we sat

matter, that he designed allthat testing because we

down and said , " Now , this is what we're going to do."

did the tests, and we didn 't talk to one another, and

This was known to us through the various conversations

the results were the results, you know . But that 's

and meetings leading up to that.

how that went. It was very controlled

And it would be a process where the

Q Give mean example of how hewould control

manufacturers would each submit an instrument for us

that, if you can recal.l

to test, if you will, and see if itmet the

A . Sure. Wehad a white board in the lab , and

specifications on RFP . Wewere each supposed to

we talked about wewere going to run various values of

do our own testing and not to discuss it with one another about, hey, this one really did this or that

solution through it various number of times and do

25

that. I forget many of the things, but that was one

22

24

one really did that. And so that was what the process was .

that hehad written up, how many times we were going to test each . And, I mean , there were -- there were

Q . Prior to yourself or anyone else reviewing

just hundreds -- hundreds and hundreds and hundreds

these devices, were you given any performance studies or any scientific studies that had been done to

these tests performed where we would , you know , check the value , I don 't know , ten -odd times on each one of

determine whether or not these machines were scientifically precise or reliable or actually did

these . So it stacked up to a large project, it really did

what they were supposed to do ? A . You know , I don't recall any specific

scientific studies . At that point it was all still

Q . Was there data being written down or captured during the evaluations --

A Yes .

sales literature. That's my recollection . Q . And so is it fair to say in the lab area

Q . -- to memorialize what was occurring ? A . Uh -huh

there atCDPHE, you wereleftto your own to conduct

Q . How was that done ?

these experiments, so to speak, to determine-- How did itwork ?

A . I don' t know how others did it . I kept it in an Excelspreadshee.t

Sure. The answer to your question is yes

Q. On your computer ?

and no, mostly no. Okay ? Yes, the concept is each of

A . Sure

you guys , so me, Jeff , and Bob, just go see if it meets these specifications , instrument A , B, C . We

Q. And was there COBRA data on that ? A . No .

had three that we tested .

Q . So, for you, it wason an Excelspreadsheet.

The reality was Jeff is

a

Would you then turn thedata over to Jeffthat you

micromanager, and Jeff - - I'm going to veer off track,

cameupwith ?

but I'm going to come back . When I first met Jeff --

A . No. Weweren ' t to talk to one another about

Jeff's a nice guy, and I' m sure he still is, very nice

24 it, really , you know . So I just keptmy own -- kept

25

man. But through the course of my employment working

25 myown notes and records and things like that.

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Because knowing how thiswas going to come down do a - - well literally a score sheet, each of the RFP items we were to score. And so, you know , I keptmy data, I assume Bob did , Jeff did. You know , that's how I did it, I just keptmy own .

Q . Was itbecause you had used CMIas a vendor and you had some familiarity with CMI, did thatmake integration with the 9000 easier than the other vendors that presented , or did it not matter ?

A . I don' t think itmattered, no. If anything, there was a familiarity with the staff. And if a question occurred during testing, with the other vendors you would call the salesperson and the salespersonwould go to engineering or whoever and get an answer and then back to the salesman and then to us. Whereas we had already access to the engineering staff at CM,I and so we would short-circuit that and get an answer to our question . So, yeah, there was an ease of use in thatmanner

Q . Did JeffGroff ever indicate to you that he had a sense of responsibility with this program taking

off ? You ' ve indicated that he' s a micromanager and there was some ego issues there. How did Jeff see this project ? Do you recall him --

A . Oh, this was going to makehis career. This

27

What types of communicationswere taking place on that?

A Thatwas -- Thatwasthe biggestfiasco as far as 'm concerned, and the mostfrustrating fiasco for mein myrole there.

The very earliest part of the project ,

before an RFP was even issued , Jeff had gone out to - sent a letter out in March of 20, Iwant to say, 11or 12, but before the RFP was issued , asking all of the agencies that used an Intox to set aside $ 10,000 per Intox .

So you can imagine Denver, which had, I think, four, somedang sheriff s office , one, whatever. And that, ofcourse, created quite a fuss. And I remember itwas March of this particular year because I had read that damn letter so many times. So that' s how that project started was when he got kind of approval to start making things move forward , he felt comfortable to send that letter out. And that --

You know , people were very upset. So we would go out and through the course

of our jobs doing facility inspections, things like that, we were beingharangued by especially the small town police chiefs and sheriffs -- sheriff. So it was very frustrating

26

28

was a career- defining project, absolutely . And he said it, yeah

Later that year it came to be -- around August or September, we came to know that a state

Q . Did he say anythingelse ? And when did that

patrol chief, whose namewasWolfinbarger, maybe, had

comeoutwhen he said this is a career-defining --

agreed to fund the whole thing or themajority of it.

A . , just in general conversation . You know ,

I think we had three grants, CSP and then two other

we would be talking about the importance of this

smaller grants; that' smy recollection . And I

project and the importance of doing each of these

remember itbecause it was the day that CSP caught - -

things right, and he would , you know , make a comment

There was somebad people on the run from the south

thatthis was something that would really define his career. He compared it to -- Hehad apparently ,

and they caught them down by Pueblo. And so itwas such a high note for CSP , and thatwas the day also

working for the department of health , brought a lab on -line up at C .U . Boulder at some point, and that was

Chief Wolfinbarger had called Jeff and said, " We're going to solve this." So it then just needed the

also another career -defining project. So he would compare the two .

governor's approval, if I remember rightwhich came in November of this particular year.

Q . Was he concerned aboutthe criminaldefense

And the frustration -- the frustration was

bar questioninghismethodsor how hewas doingthis

Jeff, in my opinion , should have notified everybody

duringthis time?

that we're funded , that we're solved . But he didn' t.

A Sure.

He just keptitmum as to how these were going to be

Q What did he say about that?

paid for. And by --

A Well, you know , he wanted us to be careful

Q . Did he tell you why?

to follow the RFP, just follow it very carefully, and we did

A . Well , you know , I would say, " Jeff, why can t we tell these people ?" He' d say, "Well, just in

Q . You indicated that he had communications

case the" - - It was just " just in case ," I think ; I

with law enforcementconcerningbringingthison- line?

don' t know . Just in case we need more money, you

A . Uh- huh

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know , or like Denver wants a fifth one, we need to

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